I agree with elsolo, EPA needs to revise their testing methodology to reflect real world conditions. Ford might well have followed EPA testing guidelines to get 47 MPG, but if so the cars were tuned only for that style of driving to get those numbers. This does Ford no good if real world conditions will always result in 10 MPG less, which is in my mind grounds for a lawsuit. Why build and advertise a car that can hit maximum EPA estimates if it's 10 MPG off in the real world? Ford screwed themselves with these overly optimistic numbers.
I think at this point, EPA guidelines are lax to allow manufacturers to get closer to hitting CAFE targets, which in turn allows big government to say it's "doing it's part" in regulating pollution.